Finding Text
84.011 MIGRANT EDUCATION PROGRAM – DEPARTMENT OF EDUCATION –COLORADO DEPARTMENT OF
EDUCATION PASS-THROUGH
2023-001 ACTIVITIES ALLOWED
1. Criteria: - Local educational agencies use funds in accordance with the agreement with the State
educational agency to (a) identify eligible migratory children and their needs; (b) provide instructional
and support services that address the identified needs of the eligible children; and (c) to support such
objectives through related activities such as, but not limited to, professional development, parental
involvement, and transfer of student records. (Emphasis added)
2. Condition: The BOCES submitted a budget that was approved by the Colorado Department of
Education outlining the expenditure of certain grant dollars for salaries and benefits to support their
Migrant Education Program. These funds were ultimately paid to an outside contractor without an
approved budget revision being submitted to the State. The costs were allowable under grant
guidelines.
3. Context: The BOCES coded these expenditures to salaries, benefits and supplies expense throughout
the year as that was how they were being billed by the third-party contractor. Subsequent to year end,
the BOCES reclassified the salary and benefit portion to purchased professional services. As this was
subsequent to year end, the BOCES could not file a budget revision with the State. Based on discussions
with the client they did not appear to be treating these payments similar to their “flowthrough” dollars
to their member district’s rather than as an independent contractor.
4. Cause: The BOCES did not correctly account for the third-party activity until subsequent to year end.
5. Effect: The BOCES spent funds for activities that were theoretically, but not actually, approved by the
State.
6. Recommendation: The BOCES should properly account for its activities both in the budget process and
in its formal accounting. This will also help ensure that any other requirements related to contracting
are also appropriately followed.
7. Management Response: Centennial BOCES will review the expected activities to ensure that they are
appropriately listed on the budget submitted to CDE for approval and properly coded throughout the
year.